On April 3, 2020, Warner provided guidance on the Paycheck Protection Program (PPP) based on the Interim Final Rule released by the Small Business Administration (SBA). Since that time, the SBA, in consultation with the Department of Treasury, issued further guidance on the PPP. The interim rules and guidance clarified some, but not all, of the open issues related to the administration of the PPP loan program.
The interim rule provides the following:
The supplemental interim final rule and accompanying guidance provide the following:
The SBA and Department of Treasury have also released FAQs concerning the Paycheck Protection Program. The FAQs are being updated on a regular basis and a link to the FAQs is provided below.
As of April 8, 2020, the FAQs include the following:
The complete list of updated FAQs can be found here.
The affiliation rules are complicated and specific to the SBA. If you have concerns about the affiliation rules, please contact Ford Turrell, Tim Hillegonds, Rob Davies, Matt Crowe or your Warner attorney.
